Searching Content indexed under Tax by Milbank LLP ordered by Published Date Descending.
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Basis Of Grantor Trust Assets At Death: What Treasury Should Do
Two years have passed since Treasury and the IRS first announced that they were working on guidance relating to the basis of grantor trust assets at death.
United States
10 Sep 2018
Treasury's Proposed Zero Basis Rule: Will It Survive?
The so-called step-up in basis at death1 and the estate tax system have long been closely linked.
United States
30 May 2018
Implications Of Election Results; IRS Inflation-Adjusted Amounts For 2017; Status Of Valuation Discount Regulations
President-elect Trump and Republicans in Congress have both called for estate tax repeal. Repeal legislation is very likely to be proposed next year and may be enacted...
United States
21 Dec 2016
Proposed Regulations Aim To Eliminate Many Valuation Discounts
The IRS has published proposed regulations that, when issued in final form, will se-verely curtail the use of valuation discounts in order to transfer interests in family-controlled entities...
United States
10 Aug 2016
IRS Notice 2016-31: Beginning Construction Under The PATH Act
On May 5, 2016, the IRS released Notice 2016-31, which clarifies the circumstances under which a taxpayer will be treated as having begun construction...
United States
13 May 2016
Implementing "Fungible" Incremental Term Loans
In many cases, borrowers and arrangers of incremental term loans desire that the incremental term loans be "fungible" with an existing tranche of term loans.
United States
10 Mar 2016
Potential PTC And ITC Extension
On the evening of December 15, the House and Senate Congressional leaders announced two pieces of draft legislation that would affect the tax credits available for renewable energy projects.
United States
24 Dec 2015
Inflation-Adjusted Amounts For 2016 Announced
In Revenue Procedure 2015-53, the Internal Revenue Service recently announced certain inflation adjusted amounts for 2016, including gift, estate, and generation-skipping transfer ("GST") tax amounts.
United States
6 Nov 2015
Pending New Regulations Will Eliminate Certain Valuation Discounts For Gift And Estate Tax Purposes
A few days ago, IRS personnel advised that they are "getting close" to issuing gift and estate tax regulations under Section 2704 of the Internal Revenue Code...
United States
23 Sep 2015
FATCA And The LMA: A Change Of Approach
The LMA have announced a change of approach to the allocation of FATCA withholding risk in certain of their precedent facility agreements.
United States
15 Oct 2014
IRS Notice 2014-46: IRS Addresses What It Means To Have Begun Construction Prior To January 1, 2014
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 which, among other things, replaced the requirement that certain production tax credit and investment tax credit eligible facilities be placed in service by the applicable credit termination date with a requirement that construction of such facilities begin before January 1, 2014.
United States
18 Aug 2014
Wells Fargo Victory Broadens Interest Netting For Merged Corporations
The United States Court of Federal Claims recently granted partial-summary judgment to Wells Fargo & Company in a significant interest netting case.
United States
16 Jul 2014
Rep. Campís Proposal Would Affect Tax Benefits For Renewable Energy Property
On February 26, 2014, a discussion draft of the Tax Reform Act of 2014 was released by House Ways and Means Committee Chairman Dave Camp.
United States
11 Mar 2014
New York Proposes Changes To The Application Of Its Estate And GST Taxes And The Income Taxation Of Trusts
On January 21, 2014, Governor Cuomo submitted his Executive Budget for 2014-2015 to the New York State Legislature - Budget Bill A8559.
United States
25 Feb 2014
Revenue Procedure 2014-12: IRS Follow-Up To Historic Boardwalk
On December 30, 2013, the Internal Revenue Service (the "IRS") released Revenue Procedure 2014-12 (the "Revenue Procedure"), describing a "safe harbor" for the allocation among partners of rehabilitation credits under section 47 of the Internal Revenue Code of 1986, as amended (the "Code").
United States
7 Jan 2014
IRS Notice 2013-60: Beginning Construction - Continuous Construction, Continuous Efforts, Master Contracts And Transfers Clarified
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 which, among other things, extended the 2.3 cent-per-kilowatthour production tax credit and the 30% investment tax credit to qualifying wind and other renewable energy facilities the construction of which begins before January 1, 2014.
United States
25 Sep 2013
FATCA And The Syndicated Loan Market Some More Breathing Space
The IRS have recently announced certain modifications to the well-known US FATCA regime, including a postponement of the first date on which the regime can impose withholding tax on affected payments and an extension of grandfathering from that withholding tax.
United States
26 Jul 2013
IRS Notice 2013-29: What It Means To "Begin Construction"
The Internal Revenue Service has recently published Notice 2013-29, providing guidance on what it means to "begin construction" under the Act.
United States
23 Apr 2013
Tax Consequences Of Re-Pricing To CLOs
Re-pricings of debt instruments have increased over the last year. Re-pricing involves resetting the interest rate of the debt instrument, with the holders either accepting the new terms or being redeemed.
United States
22 Apr 2013
FATCA 3.0 For Funds And Securitization Vehicles
The U.S. Internal Revenue Service has recently released final regulations under the so-called "FATCA" provisions found in Section 1471 through 1474 of the U.S. Internal Revenue Code.
United States
27 Feb 2013
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